Definitions of the terms used (e.g. “personal data” or “processing”) can be found in Art. 4 GDPR.
Our website is encrypted via an https connection, i.e. a secure channel is used for the transmission of data between the user’s terminal device and the server of Witten/Herdecke University, which cannot be read by unauthorized third parties.
1. name and address of the responsible person
The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection provisions is the:
Private Universität Witten/Herdecke gGmbH
+49 2302 926 0 E-Mail: email@example.com www.uni-wh.de
2. name and address of the data protection officer
Data security official contact:
Dipl.-Stat. Martin Rützler
3. general data processing
3.1. Scope of the processing of personal data
As a matter of principle, we only process personal data of our users to the extent that this is necessary for the provision of a functional website as well as our content and services. Personal data of our users is regularly processed only after their consent. An exception applies in those cases where it is not possible to obtain prior consent for factual reasons and the processing of the data is permitted by legal regulations.
3.2. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) as the legal basis
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.
Insofar as the processing of personal data is necessary for the fulfillment of a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR as the legal basis.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 para. 1 lit. f GDPR as the legal basis for the processing.
3.3. Data deletion and storage duration
The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage ceases to apply. In addition, storage may take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or fulfillment of a contract.
4. Provision of the website and creation of log files
4.1. Description and scope of data processing
Each time you visit our website, our system automatically collects data and information from the computer system of the calling computer.
The following data are collected:
IP address of the user
Access date and time
The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.
4.2. Legal basis for data processing
The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f GDRP.
4.3. Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.
The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDRP.
4.4. Storage duration
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
In the case of storage of data in log files, this is the case after two days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.
4.5. Possibility of objection and elimination
The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
5.1. Description and scope of data processing
The user data collected in this way is pseudonymized by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data is not stored together with other personal data of the users.
5.2. Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDRP.
5.3. Purpose of data processing
The user data collected through technically necessary cookies are not used to create user profiles.
The analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus constantly optimize our offer.
In these purposes also lies our legitimate interest in the processing of personal data pursuant to Art. 6 para. 1 lit. f GDRP.
5.4. Duration of storage, possibility of objection and elimination
If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.
6. Contact form and e-mail contact
6.1. Description and scope of data processing
A contact form is available on our website, which can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask will be transmitted to us and stored.
The following data is also stored at the time the message is sent:
User IP address
Registration date and time
Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user’s personal data transmitted with the e-mail will be stored.
In this context, the data will not be passed on to third parties. The data will be used exclusively for the processing of the conversation.
6.2. Legal basis for data processing
The legal basis for the processing of the data, if the user has given his consent, is Art. 6 para. 1 lit. a GDPR.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDRP. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDRP.
6.3. Purpose of data processing
The processing of personal data from the input mask serves us to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
The other personal data processed during the submission process are used to prevent misuse of the contact form and to ensure the security of our information technology systems.
6.4. Storage duration
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
6.5. Possibility of objection and elimination
The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.
Revocation of consent and objection to storage should be sent to: firstname.lastname@example.org
All personal data stored in the course of contacting us will be deleted in this case.
7. Web analysis by Matomo
7.1. Scope of the processing of personal data
We use the open source software tool Matomo (formerly PIWIK) on our website to analyze the surfing behavior of our users. The software sets a cookie on the user’s computer (for cookies, see already above). If individual pages of our website are called up, the following data is stored:
- Two bytes of the IP address of the user’s calling system.
- The requested web page
- The website from which the user has reached the accessed website (referrer)
- The subpages that are called from the called web page
- Time spent on website
- The frequency of access to the website
The software runs exclusively on the servers of our website. A storage of the personal data of the users only takes place there. The data will not be passed on to third parties.
The software is set so that the IP addresses are not stored completely, but 2 bytes of the IP address are masked (Ex: 192.168.xxx.xxx). In this way, it is no longer possible to assign the shortened IP address to the calling computer.
7.2. Legal basis for the processing of personal data
The legal basis for the processing of the users’ personal data is Art. 6 para. 1 lit. f GDRP.
7.3. Purpose of data processing
The processing of users’ personal data enables us to analyze the surfing behavior of our users. By analyzing the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to constantly improve our website and its user-friendliness. In these purposes also lies our legitimate interest in the processing of data pursuant to Art. 6 para. 1 lit. f GDRP. By anonymizing the IP address, the interest of users in their personal data protection is sufficiently taken into account.
7.4. Storage duration
The data is deleted as soon as it is no longer needed for our recording purposes.In our case, this is the case after 30 days.
7.5. Possibility of objection and elimination
We offer our users the possibility of opting out of the analysis process on our website. To do this, you need to follow the corresponding link. In this way, another cookie is set on their system, which signals our system not to store the user’s data. If the user deletes the corresponding cookie from his own system in the meantime, he must set the opt-out cookie again.
You can find more information about the privacy settings of the Matomo software at the following link: https://matomo.org/docs/privacy/.
8. Integration of third party services
We use within our online offer on the basis of our legitimate interests in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GPRD uses content or service offers from third-party providers in order to integrate their content and services, such as videos or fonts.
This always assumes that the third-party providers of this content are aware of the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content.
Third-party providers may also use so-called pixel tags for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.
We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
We integrate the maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Our website uses so-called social plugins (hereinafter referred to as “plugins”) of the social network facebook.com, operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter referred to as “Facebook”). The plugins are marked by Facebook with a Facebook logo and/or the addition “Facebook Social Plugin”.
Various web pages on our website contain such plugins, which establish a direct connection to the Facebook servers when the page is called up. If the user interacts with one of these plugins (“Like”, “Recommend”, “Comment”, etc.), it is possible for Facebook to record and evaluate the visit to certain pages. Among other things, your IP address and – if you are registered and logged in on facebook.com – your user name may be transmitted to Facebook. Facebook can therefore combine the page view with your personal data and thus identify you, whereby a collection of personal data can take place.
We can embed the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
We can embed the videos of the platform “Vimeo” of the provider Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA.
9. Data subject rights
9.1. Right to information
You may request confirmation from the controller as to whether personal data concerning you is being processed by us.
If there is such processing, you can request information from the controller about the following:
- the purposes for which the personal data are processed;
- the categories of personal data which are processed;
- the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
- the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage duration;
- the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
- the existence of a right of appeal to a supervisory authority;
- any available information on the origin of the data, if the personal data are not collected from the data subject;
- the existence of automated decision making including profiling pursuant to Art. 22 para. 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information about whether personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to. Article 46 of the GDPR in connection with the transfer.
9.2. Right to rectification
You have a right to rectification and/or completion vis-à-vis the data controller, insofar as the personal data processed concerning you are inaccurate or incomplete. The responsible party shall make the correction without undue delay.
9.3. Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:
- if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
- the controller no longer needs the personal data for the purposes of processing, but you need them for the assertion, exercise or defense of legal claims, or
- if you object to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.
Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of their storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
9.4. Right to delete
You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete such data without undue delay, if one of the following reasons applies:
- The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
- You revoke your consent on which the processing is based according to. Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDRP and there is no other legal basis for the processing.
- You create according to Art. 21 para. 1 GDRP object to the processing and there are no overriding legitimate grounds for the processing, or you lodge an objection pursuant to Art. Art. 21 para. 2 GDRP object to processing.
- The personal data concerning you has been processed unlawfully.
- The deletion of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data concerning you has been processed in relation to information society services offered pursuant to Art. 8 para. 1 GDRP collected.
Third party information
If the controller has made the personal data concerning you public and is responsible pursuant to. Art. 17 para. 1 GDRP to erase them, it shall take reasonable measures, including technical measures, taking into account the available technology and the cost of implementation, to inform data controllers that process the personal data that you, as data subject, have requested from them to erase all links to or copies or replications of such personal data.
The right to erasure does not exist insofar as the processing is necessary to
- to exercise the right to freedom of expression and information;
- for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDRP;
- for archiving purposes in the public interest, scientific or historical research purposes, or for statistical purposes in accordance with. Art. 89 para. 1 GDRP, to the extent that the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
- for the assertion, exercise or defense of legal claims.
9.5. Right of information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed about these recipients by the data controller.
9.6. Right of data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that
- the processing is based on consent pursuant to. Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDRP or on a contract acc. Art. 6 para. 1 lit. b GDPR is based on and
- the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
9.7. Right of objection
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f GDRP; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.
9.8. Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
9.9. Automated decision in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
- is necessary for the conclusion or fulfillment of a contract between you and the responsible party,
- is permitted by legislation of the Union or the Member States to which the controller is subject and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or
- is done with your express consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDRP, unless Art. 9 para. 2 lit. a or g DSGVO applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.
With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms of, and the legitimate interests of, the data subject, which shall include, at least, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
9.10. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint about the processing of your personal data by Witten/Herdecke University with the State Commissioner for Data Protection and Freedom of Information of the State of North Rhine-Westphalia (www.ldi.nrw.de).
In this case, they will inform you of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.